NB: To keep this Notice simple, we have not provided a Definition Section. Any capitalized word in this Notice that is not defined in the text itself shall have the terms defined by the GDPR in its version as of the date this Notice was last modified on.
Your privacy is important to Kering and its brands and subsidiaries ("Kering", "us", "our") and we are committed to protecting your Personal Data. This Privacy Notice ("Notice") relates to our use of your Personal Data when you interact with us through our institutional website Kering.com, social media or adverts and content on third party websites (collectively “Kering Content") or otherwise engage with us, for example by contacting Customer Services or Kering Signature, attending an event, tradeshow or other Kering event.
The relevant Kering brand that is responsible for your Personal Data will be the Kering entity that you provided your Personal Data to; however as we may share your Personal Data within our group, other Kering entities may also use your information in accordance with this Notice. This means that Kering is the Data Controller, even though the relevant Kering brand you most interact with may be a joint Data Controller for legal purposes.
For further information about the Kering entities who act as a controllers of your Personal Data, please click here: ("Controller List"). Our associated brands can be found here (the “Kering Brands"). Activities of any company (including some Kering Brands) not listed in the Controller List will not be governed by this Notice. For those Kering Brands, you should refer to a third party's privacy notice for more information about how it uses your Personal Data as the case may be.
If you have any questions or concerns about our use of your Personal Data, then please contact us using the contact details provided in the section "How do I contact Kering?" of this Notice.
We encourage you to take the time to review this Notice in full to make sure you are fully informed. However, if you only want to access a particular section of this Notice, then you can jump directly to that section:
- Who is Kering?
- What information does Kering collect about me and why?
- How does Kering use my information?
- On what basis can Kering use my information in this way?
- Does Kering share my Personal Data with anyone?
- How do I stop receiving marketing communications?
- What are my data protection rights?
- For how long does Kering keep my information?
- Does Kering transfer my information to other countries?
- Is my information secure?
- What if I access a website through a Kering Site?
- What if I access or use a social network or public forum through a Kering Site?
- I have entered a contest, promotion or survey – how do I find out more about that?
- How old do I have to be to use the Kering Sites or other Kering digital offerings?
- Does this Notice ever change?
- How do I contact Kering?
1. Who is Kering?
A global Luxury group, Kering manages the development of a series of renowned Houses in Fashion, Leather Goods, Jewelry and Watches: Gucci, Saint Laurent, Bottega Veneta, Balenciaga, Alexander McQueen, Brioni, Boucheron, Pomellato, Dodo, Qeelin, Ulysse Nardin, Girard-Perregaux, as well as Kering Eyewear as of the date this Notice was last modified. For an up to date list of the Kering brands, please refer to our Website.
By placing creativity at the heart of its strategy, Kering enables its Houses to set new limits in terms of their creative expression while crafting tomorrow's Luxury in a sustainable and responsible way.
Further information are published in our annual report and other mandatory investor documentation that can be found on the website that is governed by this Notice.
2. What information does Kering collect about me?
The Personal Data that we may collect about you broadly falls into the following categories:
• Information that you provide directly
When you engage with Kering, either online or in person, we may ask you to provide us with Personal Data about you. For example, we may ask you to provide us with your contact details to register an account with us, to sign up to receive our newsletters or information about our products or events, receive job offers or financial communications and/or to submit enquiries to us.
You may also provide us with your Personal Data in other ways, such as if you contact us in relation to employment opportunities; purchase products or communicate with us through social media or our customer services teams; join a loyalty scheme or reward program, participate in our promotions, contact us on Kering Signature, or interact with us at tradeshows or our other events. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point when we ask you to provide it. We may collect:
o Identification information, for example your first name, last name, email address, postal address, date of birth, phone number, gender, country of residence, lifestyle/interests, appearance, style, login name, password, answers to security questions;
o Transaction information, for example details regarding your transactions with us, including information about the purchases you made and the date and time that you made the purchase;
o Images and photographs, for example if you submit a picture to a competition, the Kering Sites or to social media and tag Kering or a Kering Brand, through our Women in Motions projects or when you engage with Kering via technologies such as AR, face evaluation or other tools;
o Health Information, with your explicit consent, for example information related to product usage and medical history (such as heart rate, skin condition and other features) which may be provided as part of voluntary application for fashion shows or shootings in compliance with our Chart of Ethics; and/or
o Your opinions or other information, for example if you review the products you have purchased from us, provide information about products and/or cosmetic concerns, and the brands and products you use or if you provide us with your CV when exploring your employment prospects with us.
• Information that we collect automatically
When you visit the Kering Sites, engage with Kering Content, Kering Signature or with us digitally, we may collect certain information automatically from your computer, tablet or mobile phone (a “Device"). In some countries, including countries in the European Economic Area, and in Switzerland, and the UK, this information may be considered Personal Data under applicable data protection laws and/or the General Data Protection Regulation (the “GDPR”).
Specifically, the information we collect from you automatically may include information like your IP address, Device type (i.e., make and model), unique device identification numbers, browser-type, time zone settings, broad geographic location (e.g. country or city-level location) and other technical information. With your consent, some of the Kering Sites may also collect your precise location information from your Device to provide location based services. You may change your preferences at any time by adjusting the settings on your Device.
We may also collect information about how your Device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Kering Sites and Kering Content (such as how you scroll over the Kering Sites and Kering Content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times.
Our third-party sources, and the types of information we collect from them, include:
o Our retailers, distributors and third party brand partners, for example, may pass information to us including your first name, last name, email address, postal address, phone number, gender, browsing patterns, geo-location and device identifiers, click through and other cookie data, demographic information including information about your appearance and information in relation to products purchased in stores and services requested using their websites and/or applications.
o Our technology partners and market research organizations, for example where permitted by applicable data protection law our preferred technology partners may share information with us, including your browsing patterns, geo-location and device identifiers.
3. How does Kering use my information?
We will use your Personal Data for the following purposes:
• To verify your identity, for example we may use your date of birth to determine that you are old enough to use our services, or your email address to determine if you already have an account with the relevant Kering Site.
• To provide a personalized service, for example we use your information to provide you with personalized recommendations for our products that we think you might like, tailor Kering Content to better suit your interests or, at your request and where available, to offer personalized and customized products. We will also use your Personal Data across the Kering Sites to provide a seamless user experience.
• For analytics purposes, for example we may analyze your information including your location, products and/or services requested, age, time zone, IP address and URL visited, against our wider customer base for internal business purposes, such as generating statistics and developing marketing plans, to improve our services and products, the Kering Sites and Kering Content. We may also aggregate and de-identify your information to create customer segments and share with our licensees and partners.
• To provide you with email alerts that you might be interested in (and with your consent where required), for example, we may use your information to keep you up to date with our latest products, services, surveys, announcements, upcoming events, sweepstakes, contests and other promotions and competitions via our newsletters, emails, or other communications.
• To provide the best service to our customers and clients, for example, we may use your Personal Data to process and respond to your questions and/or inquiries.
• For site optimization and management, for example we may use your Personal Data to:
o administer the Kering Sites, Kering Content and our other digital offerings, including the services
and products offered through those Kering Sites;
o ensure the security of our networks and of your information;
o customize your future visits to the Kering Sites and our other digital offerings based on your interests to ensure the most user-friendly online navigation experience;
o improve the Kering Sites and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and
provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used.
• For product development and business development purposes, for example we will use information we collect from you to improve our products and develop new products.
• For fraud prevention and detection purposes and to protect and defend the rights and property of Kering, our employees and our business partners in compliance with applicable laws, regulations and international conventions.
• For employment application purposes, for example, if you contact us in relation to your employment prospects we will use your Personal Data to consider you for current and future employment opportunities and to contact you with respect to employment opportunities at Kering that you have expressed interest in. Depending on how you contact us, a separate notice may apply to the processing of your employment prospects information (Candidacy Notice).
4. On what basis can Kering use my information in this way?
We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your Personal Data.
Generally, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally rely on one or more the following legal bases to collect and use your Personal Data:
|How we use Personal Data
|Performance of a contract, or taking steps to enter into a contract
|Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) requested services and/or products from us, we will need to use your information to provide those services and/or products that you have requested; or (ii) approached us in relation to employment opportunities, the collection and use of your Personal Data is necessary to enable us to assess your application.
|Compliance with our legal obligations
|The collection and use of your Personal Data may be necessary to enable us to meet our legal obligations. For example, if you are a business customer we need to process your information to verify your identity and undertake necessary due diligence checks.
|Pursuing our legitimate interests
|Where such processing is not overridden by your rights, we are permitted to use your Personal Data to pursue our legitimate interests, for example to operate the Kering Sites and our other digital offerings, to improve our products, the Kering Sites and our other digital offerings, to undertake marketing, or otherwise to help us achieve our purpose to empower imagination. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
|In some limited circumstances, we rely on your consent to collect and use your Personal Data. For example, we rely on consent : (i) where you have approached us in relation to employment opportunities and have provided us with sensitive Personal Data, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to creating a profile about you to send personalized e-marketing or communication from different brands within the Kering group. If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section "How do I contact Kering ?" of this Notice.
You may not always be required to provide the Personal Data that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain Personal Data from you, please do not provide us with any such information, or opt out of providing this information where applicable.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however if this changes we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions or need further information concerning the legal basis on which we collect and use your Personal Data, please contact our Data Protection Team. Details for how to contact our Data Protection Team can be found in the section “How do I contact Kering?"
Please see section “What if I access or use a social network or public forum through a Kering Site?" for further information.
6. Does Kering share my Personal Data with anyone?
We may disclose your Personal Data to the following categories of recipients:
• Within the Kering Group: We may make your Personal Data available to other entities within the Kering Group, including those entities listed on our website, to allow us to provide our services to you, for the purposes described in this Notice, or as notified to you when we collect your Personal Data.
• With third parties for marketing purposes: Certain promotions and events sponsored by Kering, or certain portions of the Kering Sites, may offer you the opportunity to consent to receive marketing communications from Kering’s business partners such as Kering’s licensors or promotion co-sponsors. If you have given your consent, your information may be used by such third party for such purposes;
• With our service providers: Kering engages third party service providers to perform functions on Kering’s behalf (for example, to support the delivery of our products, or the Kering Sites). This includes but is not limited to sharing information with the following types of service providers:
o advertising providers – including companies that provide: (i) advertising space for Kering; (ii) the provision of advertising related services, including agencies instructed to make advertising purchases on behalf of Kering, providers of ad-exchanges (a digital marketplace to buy and sell advertising space) and providers of a demand-side platform (software used to purchase advertising in an automated fashion), such as DoubleClick from Google;
o providers of marketing and customer relationship management databases and data management platforms – that enable Kering to manage your information in a safe and efficient manner;
o data analyses firms – that provide insights and help us to analyze trends using the data that we and they hold;
o customer support specialists – that provide customer support services on our behalf for Kering’s products and services;
ofulfillment companies – this include companies that coordinate email campaigns, sweepstakes, contests or promotions on our behalf;
oapplication development and web-hosting companies – to enable the Kering Sites to be hosted on the internet;
oinformation technology and related infrastructure providers;
oemail and paper mail delivery providers; and
o audit and similar corporate professional service providers.
• As part of a business transfers: Kering may disclose your Personal Data to an actual or potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding
• To comply with laws: Kering may disclose your Personal Data to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person; and
• To any other person with your consent to the disclosure and for a Legitimate Interest.
7. What are my data protection rights?
Subject to applicable data protection law (including limitations provided by that law), you may also have the following rights:
• The right to request access to Personal Data, which enables you to receive confirmation as to whether or not we are processing your Personal Data and information about that processing, and to access your Personal Data
• The right to update and/or correct inaccurate Personal Data
• The right to request that we erase (delete) your Personal Data in certain circumstances
• The right to restrict (block) the processing your Personal Data
• The right to object to our processing of your Personal Data (including any processing for direct marketing purposes) for particular reason, when the processing is based on our legitimate interests
• The right to object to our processing of your Personal Data for direct marketing purposes. More information on how to stop receiving direct marketing can be found in the section marked, “How do I stop receiving email alerts?"
• The right to request portability, which means providing you, or a third party that you designate, a machine-readable copy of your Personal Data
• The right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent
• You have the right to lodge any complaints with a relevant supervisory authority
• In some countries, you have the right to define general or specific directives regarding the fate of your Personal Data after your death
You can exercise these rights by contacting us using the information provided in the section “How do I contact Kering?" of this Notice. We respond to all requests we receive from data subjects wishing to exercise their data protection rights in accordance with applicable data protection laws and/or the GDPR and we may require reasonable documentation to verify your identity prior to granting your request.
If you have any questions or concerns about how we use your Personal Data, please do not hesitate to let us know.
8. How do I stop receiving email alerts ?
We will only send you email alerts if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive email alerts from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the email you receive, by sending us an email, or by contacting us using the contact details in section "How do I contact Kering?" of this Notice. Please note that while we will honor your request to stop receiving email alerts, we will continue to send you service-related communications such as emails confirming purchases through the Kering Sites and keep your information for record keeping purposes.
9. For how long does Kering keep my information?
We will retain your information where we have an obligation or ongoing legitimate business need to do so (for example, to provide you with access to the Kering Sites or other digital offerings you have requested, to provide you with a product you have purchased or is under warantee, or to comply with applicable legal, tax, or accounting requirements).
When we have no further obligation or ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
10. Does Kering transfer my information to other countries?
As an international entity, for the purposes described in this Notice we may need to transfer and process internationally certain types of your Personal Data as listed above (including in countries outside the European Economic Area (the “EEA"), Switzerland and the UK), notably throughout the Kering Group and to the jurisdictions in which those entities are based, as listed on our website. This means that when we process your Personal Data we may process it in any of these countries.
As a result, your information may be transferred to and/or processed in countries that are not considered by the European Data Protection Authority to provide adequate protection to Personal Data, or may not guarantee the same level of protection for Personal Data as the country in which you reside. However, we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Notice. This includes implementing the European Commission's Standard Contractual Clauses for transfers of your Personal Data between our group companies, and with our third party service providers, partners and other suppliers, which require all group companies to protect Personal Data that they process from the EEA in accordance with European Union data protection law.
11. Is my information secure?
We understand that you care how your Personal Data is used and/or shared with others, and we value your trust and seek to safeguard your Personal Data.
We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards with the objective of protecting your Personal Data from unauthorized access, use and disclosure. To ensure the security of your Personal Data, we communicate our privacy and security guidelines to all Kering employees and enforce privacy safeguards within the Kering Group.
The measures we use to protect your Personal Data are designed to provide a level of security appropriate to the risk of processing your Personal Data. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective.
12. What if I access a website through a Kering Site?
As described above, the Kering Sites may contain links to and from other third-party websites and services (collectively, “Third Party Sites") that are not controlled and operated by us.
13. What if I access or use a social network or public forum through a Kering Site?
The Kering Sites may facilitate easy access to certain social networking Third Party Sites and other websites or services with user-generated content features, such as Facebook, Instagram and Twitter (“Social Sites"). You understand that we do not control such services and are not liable for the manner in which they operate.
The Kering Sites may enable you to:
• Submit content to Social Sites: for reviews, discussion forums, message boards, photographs and other public features (“Public Forums"). We do not restrict the distribution of Personal Data that you voluntarily disclose in these Public Forums, so please be aware that any information you disclose there may be collected and used by Kering and others. For this reason, we encourage you to refrain from providing or sharing Personal Data about yourself in the Public Forums. Kering cannot prevent third parties from using such information in a way that may violate this Notice or applicable law;
14. I have entered a contest, promotion or survey – how do I find out more about that?
Kering and its preferred third party service providers or business partners may offer sweepstakes, contests, promotions and surveys (each, a “Promotion") through a Kering Site.
To learn more about the terms and conditions that apply to Promotions being run by Kering, please refer to our Promotion Terms and Conditions.
15. How old do I have to be to use the Kering Sites or other Kering digital offerings?
You must be aged 15 or over to use the Kering Sites and our other digital offerings.
We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use Kering’s products and services. We do not solicit or knowingly collect Personal Data from children aged 15 and under.
If we are made aware that we have received such information, or any information in violation of our policy, we will locate and remove that information from our records.
16. Does this Notice ever change?
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page.
When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified" date at the top of this page or by sending the new Notice to you via email, where appropriate.
17. How do I contact Kering?
If you have any questions regarding our practices or how we handle your information, please contact our Data Protection Team by sending an email to Privacy@kering.comor by post to KERING, Group
Privacy Officer, 40 rue de Sèvres, 75007 Paris, France.
Thank you for taking the time to read this Notice.
© Kering 2018